the testimony concerned the proposed training programs for hazardous waste handling. niosh recently submitted a number of studies relating to the training of workers involved in the manufacture and processing of highly hazardous chemicals. niosh conducted a course approval program for pulmonary function testing pursuant to the medical surveillance requirements of the cotton dust standard. niosh estimated that 75 to 100 hours per year are devoted to a pulmonary function testing course approval program of which 75 is secretarial in nature. niosh distributed an average of ten applications per year and approved an average of four or five applications. while this testing course approval program was mandated only for the cotton dust standard, it was clear that many employers were requesting that their spirometry technicians take a niosh approved course. the niosh pulmonary function testing program was much less detailed than the osha requirements for hazardous waste worker training, and therefore the osha time involvement per application would be greater. niosh experience indicated that there is an additional time burden associated with an accreditation of approval program. the author states that making changes, the telephone communications dealing with potential applications, opinions on new technologies, and interpretations of guidelines and responsibilities under the current training provisions regulation are all very time consuming